Starvation of a civilian population is a war crime, a crime against humanity, or an act of genocide according to modern international criminal law.[1][2][3] Starvation has not always been illegal according to international law; the starvation of civilians during the siege of Leningrad was ruled to be not criminal by a United States military court, and the 1949 Geneva Convention, though imposing limits, "accepted the legality of starvation as a weapon of war in principle".[4] Historically, the development of laws against starvation has been hampered by the Western powers who wish to use blockades against their enemies; however, it was banned in the 1977 by Protocol I and Protocol II to the Geneva Conventions and criminalized by the Rome Statute. Prosecutions for starvation have been rare.